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  • Direct engagement with the ministry of forests and logging companies

    THE BC REGISTRAR OF LOBBYISTS records show that Don Kayne, CEO of CANFOR—BC’s largest logging company—met with high level BC government officials 71 times in the last year. If government officials only heard from well-spoken, persuasive and highly paid people from the industry, they would undoubtedly get the idea that the people they meet with are happy about the way BC’s forests are being managed—except for the changes that are necessary to improve industry stability and profits.

    Obviously, to get the ministry of forests back on the public leash and working as an industry regulator acting in the public interest, government officials need to hear directly from an informed BC public. There is a long history of direct engagement with the ministry of forests by both average British Columbians and forest experts. Most report back that their ideas and engagement were largely ignored or rejected. Few report a satisfying exchange with government.

    In order to reshape how we see forests as a source of employment, change how they are used to mitigate climate change, increase how much we protect to reverse the biodiversity collapse, and recognize logging’s leading role in raising forest fire hazard and the risk of flooding, an informed citizenry needs to engage directly with government. This action group has been created to increase both the volume of engagement and the quality of those interactions. If you have prepared a presentation to the ministry of forests, or a letter to an MLA, the premier or the forests minister, send it to us and include the response you received.

  • Examples of engaging the mindustry:

    david shipway
    “Mature” hemlock and Douglas fir typical of second-growth being harvested on the Discovery Islands
    Attn: Colin Koszman/ Land Use Forester, Molly Hudson/ Director of Sustainability
    I STARTED OUT IN MY WORKING LIFE in the late ’60s, surveying cutblocks and new roads with MacMillan Bloedel on many of the lands now being managed by Mosaic—up in the headwaters of the Oyster, the Quinsam, the Campbell, the Eve and the Salmon. I witnessed the last of the valley bottom old growth being logged, magnificent cedar groves that would now be considered a national treasure, and saw the montaine plateaus of Mountain Hemlock, Yellow Cedar and Western Yew before anyone had touched them. 

    Since then, I’ve watched pretty much everything on the private managed forest land of Vancouver Island get mowed down, even where regeneration is poor, and especially in the second growth stands that were nowhere near reaching maturity. And now in an act of insanity even the third growth “pecker poles”. It’s no secret to anyone paying attention that our overcut forests are in ecological decline. It’s an easy concession now for your industry to set aside some token old growth remnants, since these areas are just the hard to reach “guts and feathers” of the great forests that once existed all over this part of the coast. But the greater crime of liquidation is now happening in immature forests. We have gone from that heroic age of the Tall Timber Jamboree to an age of weasely politicians promoting chopstick factories, in less than one human lifetime. 

    I’ve spent the last 40 years woodworking and homebuilding here on Cortes, and have watched the quality of native wood species plummet as its price keeps climbing. I’ve watched the sapwood in anything made just rot away, since it’s sugar content quickly attracts fungi and insects. I’ve noticed powder worms find their way into the widely spaced grain of second growth fir and cedar heartwood, whereas the tighter grain of resinous old growth was impervious.

    What shocks me most about the simultaneous decline of professional forestry on the coast is this complete ignorance about wood quality. Foresters seem to be operating on the obsolete myth that an 80 year old Douglas Fir or Red Cedar is a “mature” tree, when it is really just an adolescent. At the “culmination age” of mean annual increment, these trees may be growing volume at their fastest rate, but that also means that the sapwood layer is also at it’s maximum volume in the tree.  In other words, trees harvested at this age may be up to 50 percent sapwood that has no endurance, no longevity in wood products. Even the heartwood is unstable and full of knots. What an incredible waste of potential. What a sad lack of patience!

    Just under half of the volume of this 95-year-old tree was low-value, non-durable sapwood (lighter coloured wood on left) around the time it was harvested

    In an age of accelerating climate change, the best terrestrial carbon sinks that we must take care of are our native forests. Here on the coast, where the risk of fire is less than in the Interior, the capacity to store a huge amount of carbon at landscape levels is more achievable, and must be seen as the highest priority and professional responsibility among coastal foresters.

    I’m not saying we need to stop harvesting trees, but that we must let them grow a lot older before doing so. We need to adopt a holistic forest management regime that aims for three crucial goals at once—high carbon capture in a biodiverse ecosystem with many old growth attributes, high carbon storage in mature durable wood products and high quality artifacts, and the economic perpetuation of good honest forestry and our inherited multitude of traditional woodworking crafts.

    What professional foresters must not continue to do is steal the young forests and future forest livelihoods from all our grandchildren, just to keep adults in luxury, while simultaneously spouting the deceptive language of sustainability. The current rapid liquidation of the immature second and third growth forests on the BC coast is just that, a trans-generational crime of grand theft that I hope will not go unpunished.

    David Shipway

    Martin Watts
    Comments submitted to Chief Forester Diane Nicholls by Martin Watts RPF, March 4, 2022
    It is unfortunate that Teal-Jones chose not to respond to 8 questions asked on February 18, 2022 (see questions below) to clarify some items in Management Plan #5. It is more than a bit disconcerting that some of the issues related to the questions asked had not already been identified by Ministry of Forests, Lands, Natural Resource Operations and Rural Development (“Ministry”) staff during the draft base case scenario review.
    1. In the last Allowable Annual Cut (AAC) determination for TFL 46, one of the harvest flow objectives was to harvest at least 200,000 cubic metres per year from second-growth stands. In Management Plan #5 this objective has been changed to harvesting a maximum of 180,000 cubic metres per year from old- growth stands.
    Based on the current and proposed AAC of 380,000 cubic metres per year, the difference between the harvest flow objectives is meaningless. Where it could have meaning is if the Chief Forester reduces the AAC. For illustrative purposes, suppose the Chief Forester reduced the AAC to 250,000 cubic metres per year. The previous harvest flow objective would only allow 50,000 cubic metres per year of old-growth stands to be harvested, whereas the proposed harvest flow objective would allow 180,000 cubic metres per year to be harvested from old-growth stands.
    More importantly, the change in the harvest flow objective signals Teal-Jones’ intent to liquidate the old-growth stands as quickly as possible, before the government has finalized its plans on old-growth. Figure 4.3 on page 12 of the Timber Supply Analysis Technical Report (Appendix C) indicates most of the old-growth available for harvest will be harvested within the first 15 years.
    Given that there appears to be sufficient second growth to harvest over the first few years of the period covered by this AAC determination, it seems reasonable to simply delay the harvest of old-growth stands that have not already been deferred from harvesting until the government has completed its work with First Nations and finalized plans on old-growth.
    2. Section 9.2.5 (Fisheries-Sensitive Watersheds) of the Information Package sets maximum clearcut equivalent areas (ECAs) for fisheries-sensitive watersheds (Hatton Creek—42%; Hemmingsen Creek—25%; Gordon River—30%).
    There is no mention of a watershed assessment in the documentation provided by Teal- Jones. I ask the Chief Forester to review how the maximum ECA limits were determined for the fisheries-sensitive watersheds. If a hydrological assessment was used, whether the assessment follows the new guidelines for Watershed Assessment and Management of Hydrologic and Geomorphic Risk in the Forest Sector.
    The timber supply analysis has used a stand height of 9.0 m for full hydrological recovery (zero percent of the area contributing to ECA). Current coastal hydrological recovery curves have a stand height of 36.0 m for full hydrological recovery.
    The current hydrological recovery curves for the coast indicate a stand height of 9.0 m represents 33.7 percent hydrological recovery, with 66.3% of the area contributing to the ECA and not zero as used in the analysis.
    Given that Teal-Jones would not provide a response, I ask the Chief Forester to review whether maximum ECA limits are exceeded in fisheries-sensitive watersheds when the correct hydrological recovery curves are used and if so, to make any necessary adjustments in the AAC determination.
    3. The timber supply analysis defines existing managed stands as stands 65 years of age or younger as of 2020. Stands older than this are defined as existing natural stands. Yields for managed stands are derived using TIPSY and yields for natural stands are derived using VDYP7.
    Section 4.2.1 (Phase II Statistical Adjustment) of the Information Package provides the statistical adjustment ratios used in the analysis. Appendix B of the Information Package provides the 2013 VRI Phase II Statistical Adjustment Report that Section 4.2.1 is based on.
    Based on Appendix B, the adjustment ratios for new merchantable volume in Section 4.2.1 are the adjustment ratios for site index and not net merchantable volume. I ask the Chief Forester to confirm that the correct adjustments were made to net merchantable volume for the timber supply analysis.
    Appendix B indicates that immature are stands less than 81 years old and mature are stands 81 or older. The adjustment ratios for VDYP7 are based on this classification. The classification is different from the definition of existing managed stands (65 years old or younger) with yield curves derived using TIPSY and existing natural stands (older than 65 years) with yield curves derived using VDYP7. I ask the Chief Forester to confirm that the application of adjustments to VDYP7 yields is statistically valid.
    4. Section 7.1 (Site Index Adjustments) of the Information Package indicates SIBEC was used for site indices for existing and future managed stands.
    Section 4.1 (Spatial Data Input) of the Information Package indicates the 1995 Teal Cedar Terrestrial Ecosystem Mapping (TEM) and the 2020 Provincial Site Productivity Layer (PSPL) were used in the analysis.
    It is unclear whether the TEM was used in conjunction with SIBEC or the PSPL was used to obtain the site indices used for existing and future managed stands.
    Based on Appendix B of the PSPL documentation3, the TEM (BAPID 5627) is not approved for site index estimation in the timber supply analysis. It has been superseded by the TFL 46 – South Vancouver Island TEM (BAPID 180).
    I ask that the Chief Forester confirm that an approved method was used to obtain the site indices for existing and future managed stands.
    5. Currently, just under 80% of the timber harvesting land base (THLB) is classified as existing managed stands and will have yield curves derived with TIPSY. The remaining 20% of the THLB will have yield curves derived with TIPSY once it is harvested.
    There is no analysis validating TIPSY current yields or future yield projections with measured ground data.
    The VRI Phase II Statistical Adjustment Report (Appendix B) used VDYP7 to estimate yields for the immature stands.
    Appendix A indicates 92 – 11.28 m radius plots were established in stands 30 to 120 years old for a site index adjustment project. It is most likely that these plots were part of a monitoring program and could be used to validate the TIPSY yields.
    It appears that TIPSY yields could have been validated using the VRI and monitoring plots 65 years or younger.
    Section 5 (Timber Supply Analysis) of the Proposed Management Plan #5 and Section 6.6 (Minimum Harvest Age) of the Timber Supply Analysis indicate that both the short-term and long-term harvest levels are sensitive to an increase in minimum harvest age:
    Increasing the minimum harvest age by 10 years reduces the short-term harvest level by 5.2 percent and reduces the long-term harvest level by 4.5%
    Increasing the minimum harvest age by 20 years reduces the short-term harvest level by 25.5 percent and reduces the long-term harvest level by 13.4%
    Given the effect of minimum harvest age on the AAC and minimum harvest age mainly affects TIPSY yields, not validating managed stand yield adds a great deal of uncertainty to the AAC determination.
    I ask that the Chief Forester request a validation of the managed stand yields using available data and a statistically valid methodology.
    6. Section 7.9 (Silviculture History) of the Information Package indicates summaries of well-spaced stems were used to initialize TIPSY simulations.
    The current methodology used by the Ministry for the TSR for Timber Supply Areas (TSAs) uses total stems from the RESULTS data.
    Given the effect of managed stand yields on the AAC, I ask that the Chief Forest review the use of TIPSY in relation to how TIPSY is used in the TSAs.
    7. Section 6.4 (Future Stand Yield) of the Timber Supply Analysis is a sensitivity analysis that increases the managed stand yield by 10% and decreases the managed stand yield by 10% to examine the uncertainty associated with managed stand yields.
    No rationale is given for the ±10% sensitivity levels and there is no validation of the managed stand yields to base a sensitivity level on.
    I ask that the Chief Forester request a validation of the managed stand yields using available data and a statistically valid methodology that will provide a sensitivity level based on the data available, such as analysis of equivalence.
    8. Appendix A of the Information Report provides a site index adjustment from 2000. Section 6.8 (Site Index Adjustment) of the Timber Supply Analysis provides a sensitivity analysis using the site index adjustment report estimates of site index for managed stand yield curves instead of the SIBEC site indices.
    This leads to an initial harvest that is 14% higher than the base case and a long-term harvest that is 36% higher than the base case.
    Site index adjustments such as this are no longer accepted in the TSR for TSAs and should also not be accepted for TFLs.
    If the Chief Forester wants to consider this sensitivity, I ask that a table like the one in Section 7.1 (Site Index Assignments) of the Information Package be prepared and compared. A cursory comparison of the site indices from the report to those in Section 7.1 do not seem to support the magnitude of difference shown in the sensitivity analysis, but they are difficult to compare as the site index adjustment report is by species and BEC and Section 7.1 is just by BEC.
    Martin Watts MScF, RPF FORCOMP Forestry Consulting Ltd
    Questions sent via email from Watts to Teal Cedar Products Ltd that remain unanswered:
    I will be submitting some comments on Management Plan #5, but would like to clarify a few items first:
    1. In the 2011 AAC determination, it indicates one of the harvest flow objectives was to harvest at least 180,000 m3/year from second-growth stands (age 55-249).
    In the current timber supply review, it indicates one of the harvest flow objectives is to limit harvest to 180,000 m3/year from old-growth stands (age 250+).
    Are these harvest flow objectives:
    a) Voluntary (set by the licensee),
    b) A soft partition recommended by the Chief Forester, or c) Something else?
    2. The Site Index Adjustment Report (Appendix A of the Information Package) indicates 86- 11.28 metre radius plots were established in 1995 to obtain site index information for stands 21-120 years old.
    I assume that these were intended as monitoring plots and include tree measurements that can be used to validate managed stand yield projections. Is this correct?
    Have these plots been re-measured since 1995?
    3. The VRI Phase II Adjustment Report (Appendix B of the Information Package) indicates volumes from immature (age 30-80 years) plots were compared to VDYP7 estimates.
    Section 7.6 (Yield Table Development) of the Information Package indicates TIPSY was used to generate yield curves for managed stands (stands established since 1955).
    Is there an analysis available that compared the immature VRI plot volumes to TIPSY estimates and if so, can it be provided?
    Is there an analysis available that compares the volumes of the plots established for the site index adjustment to TIPSY estimates and if so, can it be provided?
    4. What is the rationale behind using ±10 percent as a sensitivity analysis for managed stand yields?
    The VRI statistical analysis indicates managed stand volumes are over-estimated by far more than 10 percent.
    5. Section 9.2.5 (Fisheries Sensitive Watersheds) of the Information Package indicates a stand height of 9.0 metres is used for full hydrological recovery (ECA is zero percent).
    This appears to be from out-of-date hydrological recovery curves. Current coastal hydrological recovery curves have a stand height of greater than 36.0 metres for full hydrological recovery.
    The current hydrological recovery curves for the coast indicate a stand height of 9.0 metres is only 33.7 percent hydrological recovery.
    If current hydrological recovery curves for the coast are used, is the maximum ECA in the fisheries sensitive watersheds exceeded in the base case scenario?
    6. Table 4.1 of the Information Package indicates TEM is based on a 1995 project conducted by Teal Jones, but also listed the 2020 Provincial Site Productivity Layer (PSPL).
    Section 7.1 (Site Index Assignments) of the Information Package indicates SIBEC was used to estimate site index for managed stands (stands that regenerated after 1955).
    Was the PSPL or the 1995 TEM and SIBEC tables used to assign the managed stand site indices?
    If the 1995 PEM and SIBEC tables were used, are there significant differences in BEC estimation between the PSPL and 1995 PEM?
    7. Table 7.1 (Analysis Unit Site Index) of the Information Package lists the area-weighted site indices for the analysis units (the BEC assignment for analysis units is a bit different from that given in table 6.2).
    Is there a similar table for the site indices from the site index adjustment project?
    The differences in managed stand yields, depending on the source of managed stand site indices, seems high based on a cursory comparison of the differences in SIBEC versus site index adjustment site indices.
    8. Section 7.9 (Silviculture History) of the Information Package indicates summaries of well- spaced stems were used to initialize TIPSY simulations.
    The current methodology used by FLNRO for the TSR uses total stems from the RESULTS data.
    What is the rationale for using well-spaced stems?

    Yves Mayrand
    This is the executive summary of a 42-page submission:
    Teal Cedar Products Ltd. (Teal-Jones) is the holder of Tree Farm Licence 46 (TFL 46), which it acquired from Timber West in 2004. TFL 46 is located on the west side of South Vancouver Island near Port Renfrew, on provincial Crown land covering unceded First Nations traditional territories. Its 10-year Allowable Annual Cut (AAC) is currently subject to a timber supply review (TSR) by the Chief Forester as mandated by the Forest Act (BC). The TSR process requires a public comment period on Teal-Jones’ management plan that includes a Timber Supply Technical Analysis Report stating the licensee’s proposal to the Chief Forester for a new AAC determination for TFL 46.
    There are significant and unexplained issues with Teal-Jones’ conduct during this TSR process, which has extended well beyond the expiry date of the latest 10-year AAC determination for TFL 46, while Teal-Jones continued its timber harvesting activities within TFL 46 and will likely continue to do so until a new AAC determination is made. There are also several significant deficiencies in the information provided by Teal-Jones for public review and comment.
    The information provided by Teal-Jones does however clearly show that the timber resource in TFL 46 has been over-harvested by Teal-Jones during its tenure. Teal-Jones formally acknowledges the “precarious nature of the timber supply situation” in TFL 46. Yet, Teal-Jones proposes a new AAC with a higher annual volume of timber harvesting for TFL 46 for the next 10-year period. In the circumstances, the proposal of Teal-Jones to the Chief Forester will also prove to be unsustainable.
    Furthermore, Teal-Jones clearly intends to clearcut all the available old growth tree stands still remaining within TFL 46 essentially in the next ten years without regard for old growth logging deferrals and without regard for the resulting adverse consequences, particularly with respect to the required protection of the natural old growth habitat for the Marbled Murrelet, a bird species protected under the authority of the Species at Risk Act (Canada), as well as an order and notice respectively issued under the authority of the Land Act (BC) and the Forest and Range Practices Act (BC). At-risk old growth forest ecosystems with very large and healthy old trees having several centuries of age, and even more than 1,000 years of age, are directly threatened by Teal-Jones’ proposed management plan for TFL 46.
    For these reasons, the new AAC determination for TFL 46 to be made by the Chief Forester (or Deputy Chief Forester) should: 1) be set for a period that is shorter than the maximum 10-year period permitted by the Forest Act (BC); 2) be set at a significantly lower annual volume level than the annual volume set in the previous AAC determination and the annual volume proposed by Teal-Jones; 3) include a partition setting separately the allowable timber harvesting volume for areas of second growth and areas of old growth within TFL 46 for the duration of the shorter AAC period; and 4) specifically exclude from the Teal-Jones timber harvesting land base (THLB) and the AAC for TFL 46 the old growth areas on provincial Crown land that are: (a) already subject to logging deferrals under the authority of the Forest Act (BC); (b) subject to further logging deferrals pending consultations with First Nations; and (c) necessary to effectively protect the natural habitat of the Marbled Murrelet pursuant to federal and provincial law.
    Full submission: Comments on the TSR Information Package and Forest Stewardship Plan of Teal Cedar Products Ltd. - Yves Mayrand - Corrected March 1, 2022.pdf
    Chief Forester Diane Nicholls’ response: Chief Forester Reply to Submission on TSR for TFL 46 - March 22, 2022.pdf

    Roger Wiles
    ...including Teal Cedar's response.
    TEAL CEDAR PRODUCTS LIMITED is seeking public consent for the continued liquidation of primary forests within Tree Farm Licence 46 lands. Public interest demands that the BC Government deny them permission to execute these cutting rights. The public interest is not served by the terms of this arrangement for diverse reasons: economic, environmental, and societal. Indeed, the greater public interest is irreparably and profoundly harmed by the terms of this licence tenure.
    Tree Farm Licences are an archaic vestige of a time when government resource policy attempted to cultivate a mutually beneficial alignment of private corporate interests with what was seen to advance the public welfare. In the case of TFL 46, this meant building mill capacity, creating employment, strengthening rural communities, and cooperatively blending forest management on the extensive private forest land base of Vancouver Island in conjunction with adjacent Crown lands. Of course this extension of colonial “enclosure” was politically promoted in the guise of pushing back the frontier to forge a modern industrial society. This social engineering project was conducted while completely ignoring Indigenous cultural land rights. The lands were quite simply confiscated. We are now more than ever keenly conscious of this injustice since the adoption of the United Nations Declaration on the Rights of Indigenous Peoples.
    The TFL 46 landscape has changed over the last 70 years. Its legal boundaries have been added to and subtracted from—mostly subtracted because of private land relinquishment and take-back policy. The contractual conditions have been greatly altered to the advantage and convenience of a very few corporate players and the simultaneous disadvantage of the public interest. The biophysical condition of the TFL 46 land base has markedly declined as a result of roading, clearcutting, and monocultural planting. These extensive alterations have undermined landscape hydrology, ecosystem integrity, and viewscapes. Indeed, over the decades, the health of TFL 46 land has been degraded to such an extent that its ultimate remediation and ecological survival is problematic.
    The accompanying socio-economic exactions have wrought destruction on rural communities. As a former forest industry worker, I am but one collateral casualty among hundreds and understand how wrenching the trauma can be.
    As government policy shifted away from overseeing the TFL framework, it relinquished such requirements as “appurtenancy”—links that connected the forests and local manufacturing. TFL 46 fibre, formerly committed to the Youbou Lumbermill, was suddenly and mysteriously extinguished at the stroke of a Forests Minister’s pen. (Minister Zirnhelt later sheepishly admitted on the steps of the legislature that it was an unwitting blunder. 1)
    The loss of appurtenancy was but one example of the government retreating from its fiduciary responsibility to the public interest. Over time, an increasingly compliant (or complicit—think R.E. Sommers) government buckled to the pressures, blandishments, and/or enticements of industry. The government’s modus operandi was politely termed “sympathetic administration” and later “professional reliance.” This was an apparent naive trusting that the good folks in the forest industry would treat the public domain honourably and pay their fair share of stumpage into the roadside honesty box.
    Government abnegation from TFL responsibilities was matched by forest industry consolidation, employment contraction, and escalating log exports. Along the way, the forest economy has spiralled down to a ghostly remnant. Forest district office closures and staff reductions mean that local oversight or compliance enforcement is nonexistent. Manufacturing jobs have disappeared and communities have been hollowed out or abandoned entirely. It is estimated that at least 80 manufacturing plants have closed in BC since 2000.
    The Youbou Lumbermill was shuttered in January 2001 and that helped ease the way for TimberWest Forests to freely auction off TFL 46 without public consideration in 2004. Teal Jones was the successful bidder. It seems that their $18 million dollar investment has proven most rewarding though their actual profitability is hidden behind a private company veil.
    Economically, the wage base supported by TFL 46 is now miniscule. Distributed benefits that once accrued to rural communities are no more. Between 2000 and 2020, direct forest industry employment in BC dropped by 50 percent. Recent research definitively shows that the forest industry’s oft-repeated claim that “forestry pays the bills” in this province is a fiction. Not only did forest industry revenue not even cover the cost of forest management, but the public has actually subsidized the industry to the tune of $3.44 billion between 2010 and 2019.
    This economic withering of the forest sector—and its impact on employment and communities—shows that it is time for the government to rethink provincial forest policy. Specifically, in the case of TFL 46, cutting rights held by Teal Cedar should be suspended pending careful reconsideration of the allowable annual cut (ACC). Arguably, a case could be made for allowing a reduced ACC based on existing volumes from second-growth plantations; however, this requires closer examination. Some of these plantation lands may be better utilized for old-growth recruitment. Ecosystem services, biodiversity, landscape connectivity, and carbon storage are far more valuable to the public purse, as these values enhance sustainability and resilience in a timeframe measured not by decades but hundreds of years.
    Critically, government now has more than just socio-economic considerations to recognize and rationalize. The climate has changed and we are in the midst of an environmental emergency. Earth’s biodiversity is in crisis. Natural systems are teetering. Ecosystem services are straining. Species numbers are declining and in some cases genotypes are disappearing. Carbon sequestration is now recognized to be critical if we are to avert the worst of the soaring “greenhouse gas” effect. The UN Secretary-General Antonio Guterres announced that the Intergovernmental Panel on Climate Change’s Working Group Report was nothing less than a “code red for humanity. The alarm bells are deafening, and the evidence is irrefutable.”
    In BC we are not doing all we can to confront this existential threat. Indeed our forestry sector is quite out of step with this present peril. BC forests, as a whole, are now playing a negative role. Their forest carbon sequestration capacity is less than zero. Primary, old-growth and ancient forests are of particular concern to leading ecologists as the work of Price, Holt, and Daust has independently shown. The BC Government did react to public pressure by initiating the Old Growth Management Strategy Report. Among the public submissions was one from the Cowichan Watershed Board. It’s co-chairs wrote about their great concern for the loss of old-growth forests on southern Vancouver Island and the lack of government supervision in monitoring and enforcement. Aside from a timid, temporary deferral on cutting some old-growth polygons, the importance of the OGM recommendations has yet to be consequentially acted upon.
    The liquidation of primary forests (both old growth and other) poses substantive risk to biodiversity and forest carbon sequestration. By continuing to road and cut TFL lands, we undermine our collective resilience to the climate change onslaught. Based on BC Government statistics, the carbon arithmetic makes it very clear that we must immediately commence securing the carbon-fixing capacity of our forests.
    To summarize, our economy, environment, and civil society, and humanity as a whole, require massive consequential changes to BC provincial forest policy. This transformation should commence with an immediate denial of tenure renewal in the case of TFL 46.
    Finally, because this “proposed management plan” is about social licence and not just AAC, I draw your attention to the citizen blockades that have populated this particular TFL at the invitation of Pacheedaht First Nation Elders over recent months. This outcry from such a broad coalition of civil society, conducted with such grace and peaceful dignity, epitomizes the humanistic non-violent tradition of civil disobedience. Their call of “worth more standing” is a clarion appeal to our best nature.
    Roger Wiles has a background in forest land inventory with the Canadian Forest Service and the New Zealand Forest Service in the 1970s. He later worked as a power engineer at the Youbou Sawmill and has lived in the Cowichan Valley for the last 40 years.
    1. May 14, 2003 Cowichan News Leader (Jennifer Mclarty): “Zirnhelt—reached at his home in Beaver Valley yesterday—continues to maintain the loss of Clause 7 was 100 percent inadvertent. ‘It could well be I was advised by staff it was nothing of consequence’ he said, adding ‘under normal circumstances a high level meeting would have been set up. I am not trying to duck out of that at all. We have to stand by what we’ve done.’”
    Teal Cedar’s response to Roger Wiles’ submission:

    Evergreen Alliance Staff
    In 2018, Anthony Britneff and Martin Watts, both registered professional foresters, made a 134-page joint submission to a panel of forest scientists and professionals assembled to investigate concerns Britneff had expressed in writing to forests minister Doug Donaldson.
    Britneff and Watts summarized their concerns in a 20-page report prepared for Focus, outlining numerous problems associated with the data used to inform provincial timber supply reviews. That summary is included below.
    Britneff-and-Watts-2018-submission-to-the-Forest-Inventory-Review-Panel (summary).pdf

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